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www.acor.org.au
ABN: 60 574 301 921
31 August 2023
Industrial Chemicals Environmental Management Section (IChEM Section)
Department of Climate Change, Energy, the Environment and Water
GPO Box 3090
Canberra ACT 2601 via: ichems.enquiry@dcceew.gov.au
To Whom It May Concern
Proposed scheduling decisions under the Industrial Chemicals Environmental Management Standard
(IChEMS)
The Australian Council of Recycling (ACOR) supports the Australian Government’s steps towards controlling harmful chemicals at the source—that is, at the stage of production and distribution. The traditional approach of managing chemicals of concern at ‘end of pipe’, through the waste management and the recycling sectors, is a fundamental impediment to the Australian Government’s policy objectives for a circular economy.
ACOR is the peak industry body for the resource recovery, recycling, and remanufacturing sector in
Australia. Our membership is represented across the recycling value chain, and includes leading organisations in advanced chemical recycling processes, CDS operations, kerbside recycling, recovered metal, glass, plastics, paper, textiles and e-product reprocessing and remanufacturing, road recycling and construction and demolition recovery. Our mission is to lead the transition to a circular economy through the recycling supply chain.
We fully endorse a nationally consistent approach to managing the chemicals of concern proposed to be scheduled as essential for protecting public health and the environment.
Australia's governments have prioritised a transformation to a circular economy; however, resource recovery efforts will be severely restricted if the risks posed by harmful chemicals are not effectively managed at the source, while carefully considering measures to be applied to resource recovery at ‘end of pipe’.
Regulation placed solely on recycling creates an unequal playing field between virgin/raw and recovered resources, which can stymie efforts to lift resource recovery rates and meet National Waste Policy Action
Plan and circular economy targets.
Recovery of organic waste is a national priority to lower greenhouse gas emissions. Halving the amount of organic waste sent to landfill by 2030 is a target of the National Waste Policy Action Plan, and strategies to lift organics recovery rates include the Food Waste for Healthy Soils fund, and the prioritisation of FOGO kerbside collection.
To ensure the safety of all resources, our strong recommendation is that testing and monitoring requirements for the harmful chemicals under consideration are uniformly applied to all materials applied to land: virgin/raw products as well as recovered resource equivalents. Given the likelihood that PFAS is present across the board—including chemical fertilisers, pesticides, and herbicides—it is imperative that we take a uniform approach to protect human and environmental health, and do not disadvantage recovered materials by subjecting them to higher regulatory stringency than virgin products.
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There is a need to include greater clarity and certainty on roles and responsibilities to implement consistent monitoring and treatment regimes across PFAS contamination streams and networks. This would also help to ensure that costs associated with managing contamination are shared fairly across supply chains and jurisdictions and not solely borne by the waste management and the recycling sectors.
While acknowledging the importance of adhering to international best practices for managing risks associated with sensitive pathways, it is essential to have a comprehensive and consistent understanding of such risks. In the organics recovery context, the existing FSANZ market basket survey findings show that levels of PFAS in food within the Australian market are below the proposed maximum limits set for PFAS by the EU.
There is a high degree of uncertainty, and limited available technologies and processes to support the management of impacted resources. A lack of available or cost-effective testing methods would either lead to delays in achieving regulatory compliance or critically hinder resource recovery, resulting in unnecessarily higher levels of recyclable materials being diverted to landfill.
Given the potential to undermine broad investment in resource recovery activities, application of the precautionary principle must consider knock-on impacts and unintended consequences. Very strong evidence bases with transparent research outcomes, developed in partnership with industry, need to be provided before decisions with broad implications are made. Also, there must be clarity around how government support will be delivered, to support relevant sectors to comply with regulatory requirements in a viable and cost-effective way.
We are eager to participate in ongoing discussions and consultations aimed at striking a balance between risk and reward in resource recovery.
Yours sincerely
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